Village Clusters Housing Allocations Plan - Alternative Sites & Focused Changes (Reg. 18)

We note the proposal to increase the site boundary and an allocate an additional 5 dwellings to the site at “VC GIL1 REV Land south of Geldeston Road and Daisy Way”. The reasoned justification for the proposed change to this site relates to planning application 2022/1993, for which the Environment Agency have objected to on flood risk grounds.

We note that policy “VC GIL1: South of Geldeston Road and Daisy Way” requires developers to submit “A site-specific Flood Risk Assessment (FRA) and strategy that has regard to the issues identified in the Stage 2 VC Strategic Flood Risk Assessment (SFRA), to inform proposals for the site and preparation of a Flood Warning and Evacuation Plan”. As such, the proposed increase to the site boundary and the additional five dwellings does not currently change our objection position on flood risk grounds to planning application 2022/1993. Detailed review of any updated FRA will take place under any future re-consultation or application for the proposed site.

We do wish to highlight that there is a risk on the deliverability of this site allocation for housing until our flood risk objections are resolved.

We note that “SN4020, Land west of Old Yarmouth Road” and “VC DIT1 REV, Land at Thwaite Road and Tunney’s Lane” are both located in the catchment of the Ditchingham Water Recycling Centre (WRC). Current data shows Ditchingham WRC to be operating at close to its permitted dry weather flow (DWF) capacity, with no plans currently in place for Anglian Water to increase the available headroom to accommodate further growth in this location. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Ditchingham WRC.

We therefore recommend including within policies SN4020 and VC DIT1 REV the requirement for developers to liaise with Anglian Water and submit a Drainage Strategy as part of any future applications, demonstrating that flows from the development can be accommodated within the permitted capacity and without causing increased risk of deterioration to the status of the waterbody. The Drainage Strategy should also demonstrate that the development will not compromise the Local Planning Authority’s obligations under the Water Framework Directive and the National Planning Policy Framework’s requirement to have due regard to the River Basin Management Plan.

We note that “SN4020, Land west of Old Yarmouth Road” and “VC DIT1 REV, Land at Thwaite Road and Tunney’s Lane” are both located in the catchment of the Ditchingham Water Recycling Centre (WRC). Current data shows Ditchingham WRC to be operating at close to its permitted dry weather flow (DWF) capacity, with no plans currently in place for Anglian Water to increase the available headroom to accommodate further growth in this location. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Ditchingham WRC.

We therefore recommend including within policies SN4020 and VC DIT1 REV the requirement for developers to liaise with Anglian Water and submit a Drainage Strategy as part of any future applications, demonstrating that flows from the development can be accommodated within the permitted capacity and without causing increased risk of deterioration to the status of the waterbody. The Drainage Strategy should also demonstrate that the development will not compromise the Local Planning Authority’s obligations under the Water Framework Directive and the National Planning Policy Framework’s requirement to have due regard to the River Basin Management Plan.

We note that “SN4020, Land west of Old Yarmouth Road” and “VC DIT1 REV, Land at Thwaite Road and Tunney’s Lane” are both located in the catchment of the Ditchingham Water Recycling Centre (WRC). Current data shows Ditchingham WRC to be operating at close to its permitted dry weather flow (DWF) capacity, with no plans currently in place for Anglian Water to increase the available headroom to accommodate further growth in this location. While there may be some room for limited growth, the proposed allocations and resulting increase in foul water flows pose the potential risk of harm to the waterbody receiving treated effluent from Ditchingham WRC.

We therefore recommend including within policies SN4020 and VC DIT1 REV the requirement for developers to liaise with Anglian Water and submit a Drainage Strategy as part of any future applications, demonstrating that flows from the development can be accommodated within the permitted capacity and without causing increased risk of deterioration to the status of the waterbody. The Drainage Strategy should also demonstrate that the development will not compromise the Local Planning Authority’s obligations under the Water Framework Directive and the National Planning Policy Framework’s requirement to have due regard to the River Basin Management Plan.